Justia U.S. 6th Circuit Court of Appeals Opinion Summaries

Lamonte Jackson-Gibson celebrated his birthday with friends, including his girlfriend, Toriel Dixon, in Detroit’s Greektown neighborhood. While listening to street musicians, Sergeant Reginald Beasley and other officers asked the group to move along. Jackson-Gibson questioned the order, leading to a verbal exchange and some physical pushing. Sgt. Beasley tased Jackson-Gibson in the back while he was embracing Dixon, and both were arrested. They were charged with obstructing or resisting a police officer, and Jackson-Gibson was also charged with disturbing the peace. A jury acquitted them of all charges.The United States District Court for the Eastern District of Michigan reviewed the case. Sgt. Beasley moved for summary judgment on the excessive-force claims, arguing for qualified immunity, but did not move for summary judgment on the wrongful-arrest claims. The district court granted summary judgment on Dixon’s excessive-force claim but denied it for Jackson-Gibson’s excessive-force claim. Sgt. Beasley’s motion to reconsider was also denied, leading to this interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Sgt. Beasley’s challenge to the wrongful-arrest claims for lack of jurisdiction, as he did not seek qualified immunity for those claims in the lower court. The court affirmed the district court’s denial of qualified immunity on Jackson-Gibson’s excessive-force claim. The court held that a reasonable jury could find that Sgt. Beasley’s use of a taser was objectively unreasonable, as Jackson-Gibson’s alleged crimes were not severe, he did not pose an immediate threat, and he was not actively resisting arrest. The court also held that the right to be free from excessive force when not actively resisting was clearly established by 2019. View "Jackson-Gibson v. Beasley" on Justia Law

Timothy Hall participated in a protest in Detroit, where he was tackled and injured by a City of Detroit officer. Later, another officer ticketed him for disorderly conduct. Hall filed two lawsuits: one against the City of Detroit and another against the officers, claiming retaliation for exercising his First Amendment rights. The district court consolidated the suits, denied Hall’s request to extend the discovery period, granted summary judgment to the City, but denied the ticketing officer’s claim of qualified immunity.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the City of Detroit, dismissing Hall’s claims against the City. However, the court denied the ticketing officer’s motion for summary judgment on the grounds of qualified immunity, allowing Hall’s First Amendment retaliation claim to proceed. Hall appealed the denial of his motion to extend the discovery period and the summary judgment in favor of the City, while the ticketing officer appealed the denial of qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of Hall’s motion to extend the discovery period and the grant of summary judgment to the City. However, the appellate court reversed the district court’s decision denying the ticketing officer’s motion for summary judgment on the grounds of qualified immunity. The court held that the officer was entitled to qualified immunity because it was not clearly established that issuing a ticket under the circumstances violated Hall’s First Amendment rights. The court emphasized that the officer acted on plausible instructions from a superior and had no reason to doubt the legitimacy of the order. View "Hall v. Navarre" on Justia Law

Two sisters from Guatemala fled to the United States in 2015 after gang members threatened to maim and kill them. They entered the U.S. without inspection and were placed in removal proceedings by the Department of Homeland Security (DHS). The sisters applied for asylum and withholding of removal, claiming they were targeted due to their membership in two particular social groups (PSGs): "Guatemalan female children without parental protection" and "the Rodas family."An immigration judge (IJ) denied their applications, finding that the harm they suffered did not rise to the level of persecution, that their proposed PSGs were not cognizable, and that there was no nexus between the harm and their family membership. The Board of Immigration Appeals (BIA) affirmed the IJ's decision, assuming without deciding that the harm constituted persecution but agreeing that the gang members were motivated by financial gain rather than animus toward the family.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Petitioners' arguments regarding due process and the "Guatemalan female children without parental protection" PSG were unreviewable because they were not raised before the BIA. However, the court held that the BIA's no-nexus determination regarding the "Rodas family" PSG was inconsistent with precedents. The court emphasized that persecutors can have mixed motives, and the BIA failed to consider whether the gang members' financial motives were intertwined with the Petitioners' family membership.The Sixth Circuit granted the petition for review in part, dismissed it in part, vacated the BIA's denial of asylum and withholding of removal, and remanded the case for further proceedings consistent with its opinion. The court instructed the BIA to reconsider the nexus between the harm and the Petitioners' family membership and to address whether the Guatemalan government was unable or unwilling to control the persecutors. View "Mazariegos-Rodas v. Garland" on Justia Law

In this case, three plaintiffs—Christian Healthcare Centers, Sacred Heart of Jesus Parish, and St. Joseph Parish St. Johns—challenged aspects of Michigan’s antidiscrimination laws, alleging that these laws violated their First and Fourteenth Amendment rights. The plaintiffs argued that the laws chilled their speech and conduct, particularly regarding their religious beliefs and practices related to gender identity and sexual orientation.The United States District Court for the Western District of Michigan dismissed each case for lack of standing. The court reasoned that none of the plaintiffs had shown that Michigan’s laws arguably proscribed their speech or conduct, nor had they demonstrated a credible threat of enforcement against them. Consequently, the district court granted the defendants' motions to dismiss.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions. The appellate court agreed in part, finding that Michigan’s laws arguably forbade several of the plaintiffs’ pleaded activities. The court concluded that Christian Healthcare and Sacred Heart had plausibly established a credible threat of enforcement against them for some of the challenged provisions of Michigan’s laws. However, the court found that St. Joseph Parish had not plausibly established standing, as it failed to show a credible threat of enforcement.The Sixth Circuit affirmed the district court’s dismissal of the claims related to the Equal Accommodations Act (EAA) but reversed the dismissal of the claims related to the Elliot-Larsen Civil Rights Act (ELCRA) for Christian Healthcare and Sacred Heart. The court remanded the cases to the district court to evaluate the plaintiffs’ requests for injunctive relief. The district court’s decisions were thus affirmed in part, reversed in part, and remanded for further proceedings. View "Christian Healthcare Centers v. Nessel" on Justia Law

Kimberly Diei, a pharmacy student at the University of Tennessee Health Science Center, maintained social media accounts under a pseudonym where she posted about song lyrics, fashion, and sexuality. Her posts did not identify her as a student or affiliate her with the university. Despite this, the College of Pharmacy's Professional Conduct Committee investigated her social media activity following anonymous complaints. The Committee found her posts "sexual," "crude," and "vulgar," and ultimately voted to expel her. Diei appealed, and the Dean reversed the expulsion decision.Diei then filed a lawsuit in the United States District Court for the Western District of Tennessee, asserting violations of her First Amendment rights under 42 U.S.C. § 1983. She sought declaratory and injunctive relief, as well as damages for emotional distress. The district court dismissed her complaint, ruling that her claims for injunctive and declaratory relief were moot due to her graduation and that her remaining claims failed to state a claim for relief. The court also held that the defendants were entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court determined that Diei's claims for injunctive and declaratory relief were moot but found that her claims for damages were still viable. The court held that Diei plausibly alleged a First Amendment violation, as her social media posts were unrelated to her studies, caused no disruption, and were made under a pseudonym. The court also found that the district court improperly relied on documents not properly before it when dismissing Diei's complaint. The Sixth Circuit reversed the district court's dismissal of Diei's claims for damages and remanded the case for further proceedings, holding that Diei's speech was protected by the First Amendment and that the defendants were not entitled to qualified immunity at this stage. View "Diei v. Boyd" on Justia Law

Plaintiffs, a group of consumers, alleged that Strange Honey Farm, LLC, fraudulently marketed its honey products as "100% raw Tennessee honey." They claimed the honey was not raw, as it was heated during processing, not purely honey, as it was diluted with corn syrup, and not from Tennessee, as it was sourced from Vietnam. Plaintiffs filed a complaint against Strange Honey, its owners, and two supermarket chains that sold the honey, asserting fraudulent misrepresentation and violations of various state consumer protection laws.The United States District Court for the Eastern District of Tennessee dismissed the claims against all defendants except one, citing a lack of specificity required by Federal Rule of Civil Procedure 9(b). The court also denied plaintiffs' motion for leave to amend their complaint. Plaintiffs then voluntarily dismissed the remaining defendant and appealed the district court's decisions.The United States Court of Appeals for the Sixth Circuit reviewed the case and addressed several jurisdictional issues. The court determined that it had jurisdiction to hear the appeal because the district court's eventual entry of final judgment, after the premature notice of appeal, ripened the appellate jurisdiction. On the merits, the Sixth Circuit affirmed the district court's dismissal, finding that the plaintiffs' complaint failed to meet the specificity requirements of Rule 9(b). The court noted that the complaint did not adequately allege why the statements on the honey labels were false or when the statements were made to the plaintiffs. The court also upheld the district court's denial of leave to amend, concluding that the proposed amendments would be futile as they did not cure the deficiencies in the original complaint. View "Greer v. Strange Honey Farm" on Justia Law

Nicholas Somberg, an attorney in Michigan, was representing a criminal defendant in the 52nd Judicial District. During a virtual courtroom conference, Somberg took a picture of the Zoom meeting without the judge's permission and posted it on Facebook. The Oakland County Prosecutor filed a motion to hold Somberg in contempt for violating Michigan court rules that prohibit recording or broadcasting judicial proceedings without permission. The court dismissed the motion on procedural grounds without addressing the rule's merits. Somberg, fearing future contempt actions, sued the prosecutor, seeking a declaration that the rule violates the First Amendment and an injunction to prevent its enforcement against him.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the prosecutor, concluding that the Electronics Rule satisfied First Amendment scrutiny. Somberg appealed the decision, arguing that the rule infringes on his constitutional rights.The United States Court of Appeals for the Sixth Circuit reviewed the case and focused on the issue of standing. The court held that Somberg lacked Article III standing to pursue his claim because he could not demonstrate causation and redressability. The court noted that even if the prosecutor were enjoined from seeking contempt sanctions, the court itself could still hold Somberg in contempt sua sponte. Additionally, third parties could refer Somberg for contempt proceedings. Therefore, the court concluded that the prosecutor was not the cause of Somberg's asserted future injury, and an injunction against her would not redress that injury. The court vacated the district court's order and remanded with instructions to dismiss the case for lack of jurisdiction. View "Somberg v. McDonald" on Justia Law

James Moyer and other captive insurance agents sued GEICO, claiming they were misclassified as independent contractors and denied benefits under the Employee Retirement Income Security Act of 1974 (ERISA). They argued that GEICO should have classified them as employees, making them eligible for various benefits plans. The agents did not attach the relevant benefits-plan documents to their complaint, which are integral to their claims.The United States District Court for the Southern District of Ohio ordered the parties to provide the relevant plan documents. GEICO submitted documents it claimed governed the dispute, but the agents argued that the court could not rely on these documents without converting the motion to dismiss into a summary judgment motion and requested additional discovery. The district court disagreed, relied on the documents provided by GEICO, and dismissed the complaint, finding that the agents lacked statutory standing as they were not eligible for the benefits under the plan documents.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that there were legitimate questions about whether GEICO had provided a complete set of the relevant plan documents. The court noted issues with the authenticity and completeness of the documents, including redlines, handwritten notes, and missing pages. The court held that the district court should not have relied on these documents to dismiss the complaint without allowing the agents to conduct discovery. Consequently, the Sixth Circuit reversed the district court's decision and remanded the case for further proceedings. View "Moyer v. GEICO" on Justia Law

The case involves Ariel Schlosser, who was hired by VRHabilis, LLC (VRH) to perform unexploded ordnance (UXO) remediation. Schlosser, the only female diver, faced several incidents of alleged discrimination and harassment. She was singled out for a knot-tying test, prohibited from diving and driving the company vehicle, and subjected to verbal abuse by her supervisor, Tyler Sanders, and co-worker, Aaron Brouse. Schlosser reported the harassment, but VRH's response was inadequate, leading her to resign after ten weeks.The United States District Court for the Eastern District of Tennessee denied VRH's motion for summary judgment, allowing the case to proceed to trial. After a four-day trial and three days of deliberations, the jury found that Schlosser was subjected to a hostile work environment based on her sex or gender, in violation of Title VII of the Civil Rights Act of 1964. The jury awarded Schlosser $58,170 in back pay. VRH filed a renewed motion for judgment as a matter of law, arguing that the evidence did not support the jury's verdict. The district court denied this motion, holding that the jury could reasonably conclude that Schlosser experienced severe and pervasive harassment based on her gender.The United States Court of Appeals for the Sixth Circuit reviewed the district court's denial of VRH's renewed motion for judgment as a matter of law de novo. The court affirmed the district court's judgment, finding that the jury could reasonably determine that Schlosser was subjected to a hostile work environment based on her sex or gender. The court held that the harassment was severe and pervasive, and that VRH was liable for the actions of Schlosser's supervisor and co-worker. The court emphasized the substantial deference owed to the jury's verdict and concluded that VRH had not overcome this deference. View "Schlosser v. VRHabilis, LLC" on Justia Law

Aimee Sturgill, a registered nurse and devout Christian, objected to the American Red Cross's COVID-19 vaccination mandate, citing her religious beliefs. She requested a religious exemption, explaining that her faith required her to treat her body as a temple and avoid defiling it with the vaccine, which she believed could cause harm due to her blood clotting disorder. The Red Cross denied her request, stating that her objections were medically, not religiously, based and terminated her employment.The United States District Court for the Eastern District of Michigan dismissed Sturgill's complaint under Federal Rule of Civil Procedure 12(b)(6). The court held that she did not plausibly allege a prima facie case for a failure-to-accommodate claim under Title VII of the Civil Rights Act of 1964. The court also concluded that Sturgill did not set forth a separate disparate-treatment claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court erred by requiring Sturgill to establish a prima facie case at the pleading stage, which is not necessary under the plausibility standard set by Twombly and Iqbal. The appellate court found that Sturgill's complaint plausibly alleged that her refusal to take the COVID-19 vaccine was an aspect of her religious observance or belief. However, the court agreed with the district court that Sturgill's complaint did not set forth a standalone disparate-treatment claim. Consequently, the Sixth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. View "Sturgill v. American Red Cross" on Justia Law